Privacy Policy

With this Privacy Policy, we inform you about the processing of personal data in connection with our activities and operations, including our website under the domain name graubuenden.ch. In particular, we explain why, how, and where we process which personal data. We also inform you about the rights of individuals whose data we process.

For specific or additional activities and operations, we may publish further privacy policies or other data protection information.

We are subject to Swiss law and, where applicable, foreign law, in particular the law of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized with decision of July 26, 2000 that Swiss data protection law ensures an adequate level of data protection. With report of January 15, 2024, the European Commission confirmed this adequacy decision.

1. Contact Addresses

The entity responsible under data protection law is:

Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland

contact@graubuenden.ch

In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. We will gladly provide information upon request about the specific responsibility in each case.

1.1 Data Protection Officer or Data Protection Advisor

We have appointed the following data protection officer or advisor as a contact point for individuals and authorities regarding data protection inquiries:

Manuela Ruinatscha
Graubünden Ferien
Alexanderstrasse 24
7001 Chur
Switzerland

manuela.ruinatscha@graubuenden.ch

1.2 Data Protection Representation in the European Economic Area (EEA)

We have appointed the following data protection representative pursuant to Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

datenschutz@graubuenden.ch

The data protection representation serves as an additional point of contact for individuals and authorities in the European Union (EU) and the European Economic Area (EEA) for inquiries related to the GDPR.

2. Terms and Legal Bases

2.1 Terms

Data Subject: A natural person whose personal data we process.

Personal Data: All information relating to an identified or identifiable natural person.

Special Categories of Personal Data: Data concerning trade union membership, political, religious, or ideological views and activities, health data, intimate sphere data, ethnic or racial affiliation, genetic data, biometric data uniquely identifying a person, data on criminal and administrative sanctions or prosecutions, and data concerning measures of social assistance.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adjusting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, making accessible, organizing, structuring, saving, modifying, distributing, linking, destroying, and using personal data.

European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

2.2 Legal Bases

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (FADP) and the Data Protection Ordinance (DPO).

Where and to the extent that the European General Data Protection Regulation (GDPR) applies, we process personal data according to at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for the processing of personal data necessary for the performance of a contract with the data subject or for the implementation of pre-contractual measures.
  • Art. 6(1)(f) GDPR for the processing of personal data necessary to safeguard legitimate interests – including those of third parties – unless overridden by the interests or fundamental rights and freedoms of the data subject. Such legitimate interests include in particular the sustainable, user-friendly, secure, and reliable exercise of our activities and operations, ensuring information security, protection against misuse, enforcement of our legal claims, and compliance with Swiss law.
  • Art. 6(1)(c) GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under applicable law of Member States in the EEA.
  • Art. 6(1)(e) GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for the processing of personal data based on the data subject’s consent.
  • Art. 6(1)(d) GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.
  • Art. 9(2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subject.

The GDPR refers to the processing of personal data as the processing of personal data and to the processing of special categories of personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. Type, Scope, and Purpose of Processing Personal Data

We process the personal data necessary to perform our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The processed personal data may particularly include browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also include special categories of personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, where such processing is lawful.

We process personal data where required with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to protect overriding interests. We may also request consent from data subjects where it is not required by law.

We process personal data for as long as necessary for the respective purpose. We anonymize or delete personal data particularly depending on legal retention periods and limitation periods.

4. Automation and Artificial Intelligence (AI)

We may process personal data automatically or use Artificial Intelligence (AI) for the processing of personal data.

We may use profiling to automatically assess certain personal aspects relating to data subjects. Profiling may serve, for example, to analyze or predict interests, behavior, or personal preferences.

We inform data subjects individually about decisions that are based solely on automated processing of personal data and that produce legal effects concerning them or significantly affect them (automated individual decisions).

5. Disclosure of Personal Data

We may disclose personal data to third parties, have personal data processed by third parties, or process personal data jointly with third parties. Such third parties include in particular specialized providers whose services we use.

We may disclose personal data, for example, to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit reporting agencies, logistics and shipping companies, marketing and advertising agencies, media organizations, social organizations, telecommunication companies, insurance companies, and payment service providers.

6. Communication

We process personal data to communicate with individuals as well as with authorities, organizations, and companies. In particular, we process data that a data subject provides to us when making contact, for example by postal mail or email. We may store such data in an address book or similar tools.

Third parties who transmit data about other individuals to us are obliged to ensure data protection for those individuals independently. In particular, they must ensure that such data is correct and may be transmitted lawfully.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. With such services, we may also manage and otherwise process the data of data subjects beyond direct communication.

In particular, we use:

7. Applications

We process personal data about applicants to the extent necessary to assess suitability for an employment relationship or for the subsequent implementation of an employment contract. The necessary personal data results in particular from the requested information, for example in a job posting. We may publish job postings with the help of suitable third parties, such as in electronic and print media or via job portals and job platforms.

We also process any personal data that applicants voluntarily provide or publish, especially as part of cover letters, résumés, other application documents, and online profiles.

We process – insofar as and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular according to Art. 9(2)(b) GDPR.

8. Data Security

We take appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. With our measures, we particularly ensure the confidentiality, availability, traceability, and integrity of processed personal data, without, however, being able to guarantee absolute data security.

Access to our website and other digital presence is carried out using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn when visiting a website without transport encryption.

Our digital communication is subject – as is generally the case with any digital communication – to mass surveillance without cause and suspicion by security authorities in Switzerland, elsewhere in Europe, in the United States of America (USA), and in other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities, and other security authorities. Nor can we rule out that a data subject is specifically monitored.

9. Personal Data Abroad

We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process it there or have it processed.

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the local law ensures an adequate level of data protection according to a decision by the Swiss Federal Council and – insofar as and to the extent that the GDPR applies – also according to a decision by the European Commission.

We may transmit personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is otherwise guaranteed, particularly based on standard contractual clauses or with other suitable safeguards. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the specific legal data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or fulfillment of a contract. Upon request, we will gladly inform data subjects about any guarantees or provide a copy of any guarantees.

10. Rights of Data Subjects

10.1 Data Protection Rights

We grant data subjects all rights in accordance with applicable law. Data subjects particularly have the following rights:

  • Access: Data subjects may request confirmation of whether we process personal data about them, and if so, which personal data. Data subjects also receive information necessary to assert their data protection rights and to ensure transparency. This includes the processed personal data itself and, among other things, details about the purpose of processing, the retention period, any disclosure or transfer to other countries, and the origin of the personal data.
  • Rectification and Restriction: Data subjects may have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.
  • Presentation of Own Viewpoint and Human Review: In the case of decisions based exclusively on automated processing of personal data that have legal effects or significantly affect them (automated individual decisions), data subjects may express their own point of view and request a review by a human.
  • Deletion and Objection: Data subjects may have their personal data deleted ("right to be forgotten") and may object to the future processing of their data.
  • Data Portability: Data subjects may request the release of their personal data or the transfer of their data to another controller.

We may defer, restrict, or refuse the exercise of the rights of data subjects to the legally permissible extent. We may also inform data subjects about any requirements that must be met to exercise their data protection rights. For example, we may refuse to provide information with reference to confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse the deletion of personal data with reference to legal retention obligations.

We may charge costs for the exercise of rights in exceptional cases. We will inform data subjects in advance about any applicable costs.

We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are required to cooperate in this identification.

10.2 Legal Protection

Data subjects have the right to enforce their data protection rights through legal action or to file a report or complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), data protection supervisory authorities are federally structured, particularly in Germany.

11. Use of the Website

11.1 Cookies

We may use cookies. Cookies – both our own (first-party cookies) and those of third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data do not necessarily have to be traditional cookies in text form.

Cookies may be stored in the browser temporarily as "session cookies" or for a specific period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies enable us in particular to recognize a browser upon the next visit to our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing purposes.

Cookies can be deactivated, restricted, or deleted entirely or partially at any time in the browser settings. The browser settings often also allow for automatic deletion and other management of cookies. Without cookies, our website may no longer be fully available. We request – at least where and to the extent required by applicable law – express consent to the use of cookies.

For cookies used for success and reach measurement or advertising, a general objection ("opt-out") is possible for many services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

11.2 Logging

We may log at least the following information for each access to our website and other digital presence, provided such information is transmitted to our digital infrastructure: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, accessed individual subpage of our website including amount of data transferred, previously visited webpage (referrer) in the same browser window.

We log such information, which may also include personal data, in log files. This information is necessary to provide our digital presence in a durable, user-friendly, and reliable manner. It is also necessary to ensure data security – even with the help of third parties.

11.3 Web Beacons

We may integrate web beacons into our digital presence. Web beacons are also known as tracking pixels. Web beacons – also from third parties whose services we use – are usually small, invisible images or JavaScript scripts that are automatically retrieved when accessing our digital presence. With web beacons, at least the same information as with log file logging can be collected.

12. Notifications and Communications

12.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which links were clicked. Such web links and tracking pixels can also collect usage information on a personal basis. We require this statistical recording of usage to measure success and reach, so that we can send notifications and communications effectively, user-friendly, durably, securely, and reliably, according to the needs and reading habits of the recipients.

12.2 Consent and Objection

You must generally consent to the use of your email address and other contact information, unless the use is permitted for other legal reasons. To obtain consent, we may use the "double opt-in" procedure. In this case, you will receive a communication with instructions for double confirmation. We may log obtained consents including the IP address and timestamp for proof and security reasons.

You can generally object to receiving notifications and communications, such as newsletters, at any time. By objecting, you can also simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.

12.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

13. Social Media

We are present on social media platforms and other online platforms to communicate with interested individuals and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The terms and conditions (T&Cs) and usage policies as well as privacy policies and other provisions of the individual platform operators apply. These provisions particularly inform about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to access information.

For our social media presence on Facebook, including the so-called Page Insights, we are — insofar and to the extent that the General Data Protection Regulation (GDPR) applies — jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including the USA). The Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook effectively and in a user-friendly way.

Further information about the type, scope, and purpose of data processing, information about the rights of data subjects, and the contact details of Facebook and Facebook's data protection officer can be found in the Facebook Privacy Policy. We have entered into the so-called "Controller Addendum" with Facebook, agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. Specific information regarding Page Insights can be found on the page "Information about Page Insights" including "Information about Page Insights Data".

14. Services from Third Parties

We use services from specialized third parties to ensure that our activities and operations are carried out in a lasting, user-friendly, secure, and reliable manner. Such services allow us, among other things, to embed functions and content into our website. When embedding, the services used necessarily temporarily collect at least the IP addresses of users for technical reasons.

For necessary security-relevant, statistical, and technical purposes, third parties whose services we use may process data aggregated, anonymized, or pseudonymized in connection with our activities and operations. For example, these may include performance or usage data necessary to offer the respective service.

We particularly use:

14.1 Digital Infrastructure

We use services from specialized third parties to obtain the digital infrastructure necessary for our activities and operations. This includes, for example, hosting and storage services from selected providers.

We particularly use:

14.2 Automation and Integration of Apps and Services

We use specialized platforms to integrate and connect existing third-party apps and services. We can also automate workflows and activities with third-party apps and services using such "no-code" platforms.

We particularly use:

14.3 Appointment Scheduling

We use services from specialized providers to schedule appointments online, for example for meetings. In addition to this privacy policy, the directly visible conditions of the used services such as terms of use or privacy policies also apply where available.

We particularly use:

14.4 Online Collaboration

We use services from third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply where available.

We particularly use:

14.5 Social Media Features and Content

We use services and plugins from third parties to embed functions and content from social media platforms, and to enable the sharing of content on social media platforms and by other means.

We particularly use:

14.6 Maps

We use services from third parties to embed maps into our website.

We particularly use:

14.7 Digital Content

We use services from specialized third parties to embed digital content into our website. Digital content includes images, videos, music, and podcasts.

We particularly use:

14.8 Advertising

We use opportunities to display targeted advertising on third-party platforms such as social media platforms and search engines for our activities and operations.

We aim to reach people who are already interested or could be interested in our activities and services (remarketing and targeting). We may transmit relevant – possibly also personal – information to third parties enabling such advertising. We may also measure the success of our advertising, i.e., whether it leads to visits to our website (conversion tracking).

Third parties where we place ads and with whom you have an account may link the use of our website to your respective profile.

We particularly use:

15. Website Extensions

We use extensions for our website to enable additional features. We may use selected services from appropriate providers or operate such extensions on our own digital infrastructure.

16. Success and Reach Measurement

We aim to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party references or test how different parts or versions of our digital presence are used ("A/B testing" method). Based on the results of success and reach measurement, we can fix errors, reinforce popular content, or make improvements.

In most cases, IP addresses of individual users are recorded for success and reach measurement. IP addresses are generally truncated ("IP masking") to follow the principle of data minimization through pseudonymization.

Cookies may be used for success and reach measurement, and user profiles may be created. Such user profiles may include, for example, the pages visited or the content viewed on our digital presence, information about the size of the screen or browser window, and – at least approximately – the location. User profiles are generally created in a pseudonymized form and are not used to identify individual users. Some third-party services, where users are logged in, may link the use of our online offer to the respective user account or profile.

We particularly use:

17. Final Notes on the Privacy Policy

We created this privacy policy using the Privacy Policy Generator from Datenschutzpartner.

We may update this privacy policy at any time. We inform about updates in an appropriate manner, particularly by publishing the current privacy policy on our website.